Association for Democratic Reforms & Ors. v. Election Commission of India & Ors.
Background
In June 2025 the Election Commission of India ordered a Special Intensive Revision (SIR) of Bihar's electoral rolls, the first such exercise since 2003, requiring every existing voter to file a fresh enumeration form with supporting documents, ahead of the November 2025 Bihar Assembly elections. The Association for Democratic Reforms and several other petitioners, including political leaders and parties, challenged the exercise as unconstitutional, arguing the Commission lacked legal authority to conduct it, that it improperly required proof of citizenship (a subject for the Union Home Ministry, not the Commission), and that its rushed timeline and restrictive document list threatened to arbitrarily disenfranchise lakhs of genuine voters. During the case, the Supreme Court had already issued several interim orders, including directing that Aadhaar be accepted as a valid identity document, and by the time of final hearing the SIR exercise had already concluded and elections had been held using the revised roll (7.42 crore electors, up from 7.89 crore before revision, after roughly 65 lakh initial exclusions were substantially addressed through claims).
Decision Breakdown
The Supreme Court upheld the SIR exercise, holding it was validly traceable to Section 21(3) of the Representation of the People Act read with Article 324 of the Constitution, and was not in conflict with the statutory scheme. The Court found the exercise met the proportionality standard: its measures had a rational nexus to the legitimate goal of ensuring accurate and complete electoral rolls, were not excessive, and came with adequate procedural safeguards (notice, hearing, and appeal rights). It rejected the argument that presumption of validity attached to existing roll entries barred a systemic revision, and held the Commission's documentation requirements (including the belated inclusion of Aadhaar) were not arbitrary. On the citizenship question, the Court held the Commission may conduct a "limited enquiry" into citizenship only for the purpose of electoral-roll eligibility, this does not amount to a formal determination of citizenship, and any person excluded on that basis must be referred within four weeks to the competent authority under the Citizenship Act, 1955 for adjudication, with such exclusions remaining subject to that outcome and to judicial review.
Lesson Learnt
The Election Commission has constitutional authority to conduct periodic, intensive revisions of electoral rolls (not just routine summary updates), but this power is not unfettered. It must be proportionate, procedurally fair, and cannot be used to make a final determination of a person's citizenship, which remains the exclusive preserve of the competent authority under the Citizenship Act; a voter deleted from the rolls on citizenship grounds retains the right to have that question adjudicated separately and to seek judicial review of an erroneous deletion.